Ernst & Young's Profit From the New Tax Law | Wiley
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Leading companies trust Statista:. All Information in one Presentation. Go to dossier. Statista is a great source of knowledge, and pretty helpful to manage the daily work. The most important statistics. This also means that an application for the patent box regime by Group tax departments should be checked for consistency with existing transfer pricing documentation, i.
This is particularly important in view of the fact that DEMPE analyses are often very broad, while the scope of the patent box is relatively narrow i. Hence, it is important to record and document these relations precisely so that the pieces of the puzzle can be combined into a coherent overall picture in the event of a tax audit.
In the sense of a smooth transition from the old to the new tax regime, the TRAF provides for a mandatory two-rate model at cantonal level as a transitional arrangement to accompany the abolition of tax privileges. The hidden reserves, including goodwill created under the special tax regimes are thus subject to a separate, lower taxation for a period of five years if they are disclosed after the special status is relinquished.
It should also be considered that any possible valuation of hidden reserves could also become relevant again in the context of a potential subsequent restructuring and should therefore be examined in detail. Also in this respect, the methods used in a transfer pricing analysis can prove to be useful. In practice, this means that when hidden reserves are disclosed, a valuation can be carried out in the same way as it is carried out in an international context for a transfer of assets typically based on an income-based method, as e. The aim of this special deduction is to treat debt capital and equity equally for tax purposes.
This is worthwhile for the following reasons:. However, this measure is only possible if the effective income tax burden in the cantonal capital is at least Therefore, such deduction will presumably only be applied in the Canton of Zurich. After the tax reform bill was approved at the cantonal vote in Zurich on Sept. The equity of a legal entity consists of the core capital required by the company in the long-term and the safety equity which is not required by the companies in the long term and could theoretically be replaced by debt capital.
From a technical point of view, the safety equity represents the difference between the effectively available equity and the core capital.
Ernst & Young's Profit From the New Tax Law
The interest rate is generally based on the return for year Swiss federal bonds. However, if there are receivables from affiliated companies e. In order to determine the share of such receivables as a percentage of equity, the ratio of the average tax profit values of the receivables from related parties to assets is determined.
Such analysis i. This analysis and documentation in accordance with the international OECD standards can be used analogously at the national level and become part of the documentation for the NID application. The measures of the tax reform adopted by the Swiss electorate at federal level on May 19, , reestablishes an internationally recognized tax system in Switzerland that will at the same time guarantee the continued tax attractiveness of Switzerland as a business location. This entails the most in-depth restructuring of corporate tax law in Switzerland in recent decades which will affect virtually all companies.
Since these changes will come into force on Jan. All Rights Reserved. It can be easy for capital-allocation decisions to get buried under the many competing priorities and objectives that different groups of stakeholders bring to the table. To avoid prolonging an already labor-intensive process, finance leaders need to develop a structure and cultivate a culture that promotes productive relationships toward solutions in the best interests of the business.
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